Meta Platforms Inc v. Immersion Corp

1. Case Identification

• Case #: IPR2023-00943
• Patent #: 8,896,524
• Filed: May 25, 2023
• Petitioner(s): Meta Platforms, Inc.
• Patent Owner(s): Immersion Corporation
• Challenged Claims: 1-8 and 11-14

2. Patent Overview

• Title: Generating Haptic Effects Based on Context Metadata
• Brief Description: The ’524 patent discloses systems and methods for producing a "confirmation haptic effect" in response to a user's interaction with a user interface element. The haptic effect is customized based on "context metadata," such as the functionality or interaction history of the interface element.

3. Grounds for Unpatentability

Ground 1: Obviousness over Poupyrev and Yun - Claims 1-2, 6-8, and 11-14 are obvious over Poupyrev in view of Yun.

• Prior Art Relied Upon: Poupyrev (Patent 7,952,566) and Yun (Application # 2009/0322498).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Poupyrev discloses the core limitations of independent claim 1, teaching a touch-screen device that generates confirmation haptic effects in response to user interaction with a graphical user interface (GUI) object. Poupyrev’s system receives data about the interaction—such as touch position, pressure, and interaction history—and uses this data to determine the appropriate tactile feedback. Petitioner contended this data constitutes "context metadata" indicating a "history of the user interface element." To meet the alternative limitation of "data indicating a functionality of the user interface element," Petitioner introduced Yun. Yun teaches a mobile device that generates distinct haptic effects based on the name of a selected menu icon (e.g., a "settings" icon). This name, Petitioner asserted, indicates the icon's functionality. Dependent claims 6 and 8, which add limitations for "sensor input data" and a "virtual element," were allegedly disclosed by Poupyrev's pressure/position sensors and its use of on-screen GUI buttons.
  • Motivation to Combine: Petitioner asserted a POSITA would combine Poupyrev and Yun to enhance the user experience. Integrating Yun’s functionality-based feedback into Poupyrev’s system would allow a user to distinguish between different GUI elements through touch alone, providing a clear benefit. Both references are in the same field of haptic feedback for touch-screen devices and address the common problem of providing meaningful tactile responses to user inputs.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination, as it would involve implementing known haptic feedback techniques using rudimentary programming.

Ground 2: Obviousness over Poupyrev, Yun, Braun, and Rosenberg - Claims 2-4 and 12 are obvious over Poupyrev and Yun in view of Braun and Rosenberg.

• Prior Art Relied Upon: Poupyrev (Patent 7,952,566), Yun (Application # 2009/0322498), Braun (Patent 6,300,936), and Rosenberg (Patent 6,169,540).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds upon Ground 1 to address claims 2-4 and 12, which relate to modifying haptic parameters based on user input. Petitioner argued that while Poupyrev and Yun establish the base system, Braun and Rosenberg teach the specific user-modification features. Braun discloses a user interface dialog box with a "device gain" slider that allows a user to globally adjust the magnitude of all force feedback effects from 0% to 100%. Rosenberg, which is incorporated by reference into Braun, similarly discloses a "gain field" that acts as a "global scaling factor or multiplier for force magnitudes." Petitioner contended this user-defined percentage value is a "multiplier" as required by claim 3, and because it applies to all interface objects, it is "globally defined" as required by claim 4.
  • Motivation to Combine: A POSITA would combine Braun and Rosenberg with the Poupyrev/Yun system to provide user customization. It was well-known that users perceive haptic vibration strength differently due to factors like age or personal preference. Adding a global magnitude control, as taught by Braun and Rosenberg, would predictably improve the comfort and effectiveness of the haptic system by allowing each user to tailor the feedback intensity to their liking, creating a more uniform experience across all features of the device.
  • Expectation of Success: Petitioner argued that implementing a user-adjustable parameter via a GUI is a conventional programming task. A POSITA would have found the disclosures sufficient to implement the combination without undue experimentation.

4. Key Claim Construction Positions

• Petitioner argued that no express claim constructions were necessary because the challenged claims are obvious under their plain and ordinary meaning or any reasonable construction proposed in co-pending litigation.
• "Confirmation haptic effect": Petitioner contended this is simply "a haptic effect used to confirm the interaction with the user interface element," a feature disclosed by the tactile feedback in Poupyrev that confirms a button selection or activation.
• "Context metadata": Petitioner proposed this term means "any data associated with an interaction with the user interface element," which would encompass the position, pressure, and history data from Poupyrev, as well as the functionality data from Yun.
• "Haptic parameter": Petitioner argued this term, based on the patent’s specification, refers to a quantifiable quality of a haptic effect, such as magnitude, frequency, or waveform. Poupyrev's disclosure of controlling feedback amplitude and frequency was argued to meet this limitation.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial, noting that while the ’524 patent is subject to co-pending litigation, no claim construction or other substantive rulings had been issued.
• To address Fintiv concerns, Petitioner provided a Sotera stipulation, agreeing not to pursue in district court any invalidity grounds that were raised or reasonably could have been raised in the IPR if instituted.
• Petitioner also argued against denial under §325(d), stating that none of the prior art references relied upon in the petition were cited or considered during the original prosecution of the ’524 patent.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-8 and 11-14 of the ’524 patent as unpatentable under 35 U.S.C. §103.